August 23, 2004
I respectfully ask that you withdraw, not amend this rule proposal. Exempting broker-dealers from the Investment Advisers Act of 1940 when offering fee-based brokerage programs does not serve the publics best interest, and does not create a level playing field for advisors nor regulators. The answer, in my mind, is simple - if you wish to serve as an advisor, then meet the requirements.
Thank your for listening.